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MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge:
I. Introduction
This report concerns the affirmative defense of statute of
limitations raised by five of the petitioners in these seven
consolidated cases.2 Those five petitioners and respondent have
agreed that, at this time, respondent will not claim fraud in
response to such affirmative defense but may, at some later time,
make such response. No additional response by respondent will be
necessary, however, since, on the grounds before us, we do not
sustain any affirmative defense of statute of limitations.
The partnerships raising the affirmative defense of statute
of limitations are Agri-Venture Associates (AVA), Agri-Venture
Fund (AVF), Houston Farm Associates II (HFA-II), Dixie Venture-
1985 (DV-85), and Texas Farm Venturers (TFV). The issues we must
address are whether (1) for 1984, with respect to AVA and TFV,
and for 1985, with respect to HFA-II, a valid partnership return
was filed, which would fix the period provided for in section
6229(a) for assessing any tax, and (2) for 1985, with
2 Frederick H. Behrens, Tax Matters Partner, is petitioner
in three of those five cases, and Robert A. Wright, Tax Matters
Partner, is petitioner in the other two. To avoid confusion in
the discussion that follows, we will use the name of the
partnership, rather than the name of the tax matters partner, to
refer to the petitioner in each case: For instance, we will
refer to the petitioner in Agri-Ventures Associates, Frederick H.
Behrens, Tax Matters Partner, as Agri-Ventures Associates (AVA).
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